MRGDC | COG | TRACS Frequently Asked Questions
What is TRACS?
The Texas Review and Comment System (TRACS) is the state’s intergovernmental review system established under state (Chapter 391, Texas Local Government Code) and federal law (Executive Order 12372). Essential elements of the review system date to the 1960s and Office of Management and Budget Circular A-95. TRACS was established in 1983 when EO 12372 was issued in July 1982, authorizing states to implement their own review systems.
Why was TRACS established?
To provide an opportunity for state agencies, councils of governments and local governments to find out about and comment, if they wish, on grant applications, direct state and federal development and environmental assessments and impact statements before they are funded or approved. TRACS serves as an information exchange system, as a mechanism for improving grant applications, as a method for determining consistency with regional plans and as a check on unnecessary duplication.
Item 16 on the Standard Form 424 cover sheet for grant applications asks whether the application “is subject to review by state executive order 12372 process.” How do I find this out?
A number of federal programs are eligible for review under EO 12372. However, not all of these have been selected for review under TRACS. To find out if your program is required to be submitted for TRACS review, click on “Table I, Federal Programs Requiring TRACS Review” to see if the Catalog of Federal Domestic Assistance (CFDA) number for your grant is listed or on “Table II, State Programs Requiring TRACS Review” to see if the state program name is listed.
If my application is subject to TRACS, to whom do I send it?
The federal grant instructions say to send a copy to the State Single Point of Contact (SPOC). You only need to do this if the grant impacts are statewide or if you are an out of state applicant. Otherwise, you should contact the regional council of governments (COG) in the state planning region in which you primarily office. “Texas Counties and COG numbers” shows Texas’ 254 counties with their corresponding COG region. “State Planning Regions and Regional Councils” lists the names, addresses and telephone numbers of the 24 regional councils. COGs are the designated review entities under state law for all local and regional projects, and will provide the intergovernmental review services required by federal Executive Order 12372 and TRACS.
If my application is selected for TRACS review, how long is the review period?
Generally, the SPOC and the COGs have up to 60 days in which to conduct the TRACS review. However, typically it takes 45 days or less.
Does the review have to be completed before I submit my grant application to the federal or state funding agency?
No. If you don’t expect to have the grant application ready before the submission date to the funding agency, you may request a “concurrent review”. This means you send a copy to the SPOC or to the appropriate COG at about the same time as you submit it to the funding agency. The intergovernmental review then occurs concurrently with the funding agency’s internal review.
What happens if I get negative comments from the TRACS review?
Ideally, you should work with the COG or the agency making the comments to resolve them. TRACS is a review and comment system, however, not review and approval. Ultimately, the state or federal funding agency will make its decision based on a number of factors, including the TRACS review comments.
For a complete description of applicant responsibilities and other provisions of the intergovernmental review system, please click on TRACS Rules at this site.
Further questions should be addressed to:
- Office of the Governor
- Denise Francis
- P.O. Box 12428
- Austin, Texas 78711-2428
- Phone 512-305-9415
- Fax 512-936-2681
- State Insurance Building
- 1100 San Jacinto
- Austin, Texas 78701